What Manufacturing Leaders Must Know about OSHA Emergency Action Plans 

What Manufacturing Leaders Must Know about OSHA Emergency Action Plans 

Do you know the difference between an OSHA emergency action plan and basic workplace safety protocols? If not, you’re almost certainly putting your employees and facility at risk. 

We all know something about basic safety standards and try to minimize risks in our facilities. However, that hard work doesn’t always meet OSHA safety requirements—which means you’re gambling with your bottom line and inviting $10k-$100k+ fines every time the OSHA inspector stops by—even if you thought you knew how to prepare.

Here’s what you need to know to create a regulation-grade OSHA emergency action plan now, and reduce your risk for fines and safety violations.

What is an OSHA Emergency Action Plan?

An emergency action plan (EAP) is an OSHA-required document that facilitates and organizes employer and employee actions during workplace emergencies. Most companies, buildings, and organizations have some level of emergency action planning. What makes the OSHA EAP different is that it focuses on facilities that come with additional risk—like manufacturing plants or factories. 

A strong OSHA EAP doesn’t simply protect your workers and company in the event of an emergency; it helps prevent those emergencies in the first place and provides assistance to emergency response workers. For instance, a firefighter going into a burning home faces different risks than a firefighter headed to a chemical waste plant—and a well-executed EAP can help keep them safe. 

Is an OSHA EAP necessary? 

Yes. OSHA requires your business to have an up-to-code EAP. The complexity of that EAP might differ depending on the types of risks, materials, and number of employees at your facility, but even the smallest facilities need a plan. Not having a reliable EAP isn’t just a violation of OSHA code—it also puts your company and your employees at serious risk.   

What are the key components of creating and maintaining an OSHA EAP?

There are four key steps to creating and maintaining an OSHA EAP:

Plan Development

Developing your emergency action plan is step one of a four-step process. The trick to developing an OSHA EAP is covering your bases. You know the risks of your facility. What are the architectural risks? What are the machinery and chemical risks? Where are your exits? Where is your protective gear? How many employees do you have? How much time do they have to leave the building in the event of a fire? A chemical leak? An explosion? Even a tornado!

A good EAP doesn’t reinvent anything about your facility, it merely creates step-by-step protocols for different emergency scenarios. Remember, you might know how to turn off a machine on a normal day, but panic over a fire can wipe that knowledge right out of your head. You and your employees need to keep this vital safety information at the ready. 

Feeling overwhelmed? Start with the OSHA EAP checklist or the OSHA EAP minimum requirements. If you’re missing a few checks, regroup and fill in the gaps. You can also work with a compliance expert to develop an EAP that covers OSHA regulations while staying site-specific.  

Establishing Authorities

While your plan should be clear and straightforward for anyone who reads it, it’s always best to select one person to act as the plan authority. This person should know the plan, understand the different risks, be capable of assessing different dangers, and be able to make decisions under pressure.

No matter how thorough your plan might be, emergencies don’t follow the rules. There may be times when an employee can’t follow their part of a plan due to extreme danger—like a power line snapping. In those cases, having an established authority ensures everyone knows who to consult for guidance.

The plan must also include other responsibilities during an emergency.

Employee EAP Training and Review

Writing down your EAP is only step one. If your employees don’t know how to follow your plan, then it’s not keeping anyone safe. In fact, OSHA knows this so well they made specific codes about key training and review principles. According to OSHA code, you must: 

  • Train your employees to assist in the plan.
  • Review the plan with each individual employee.
  • Review the plan again with individual employees whenever: 
    • The employee is onboarded
    • The plan changes
    • The employee’s role in the plan changes

Additionally, general employee training should include all emergency topics, even if particular employees might not need specific bits of safety information. Those topics include: 

  • Individual responsibilities
  • General hazards and protections 
  • Notification and communication policies
  • Meeting locations
  • Evacuation procedures and exit locations
  • Locations and instructions for emergency gear
  • Basic first aid
  • Shutdown procedures (All employees, regardless of their role, should know how to shut down dangerous machinery in case of emergency.)

If your employees can’t follow your emergency action plan, it’s just as useless as not having one in the first place. And OSHA views it the same way. When it comes to safety, the importance of employee training can’t be overstated—it’s always better to have too much information than not enough. 

Regular Emergency Plan Review and Updating

Once you have your plan developed, your plan leader chosen, and your employee training completed, what happens next?

Even the best plans need reviewing and refining as regulations, equipment, and employees change over time. It’s the most frustrating part of a successful EAP—and it’s the part where most manufacturers fall short. If you’re one of those manufacturers struggling to keep your EAP updated, you’re not alone. It’s not easy to keep your EAP current, your employees trained, and your company running smoothly. 

At the end of the day, most OSHA violations aren’t intentional. They don’t happen because you want to hurt your employees or your business. They happen because you don’t have the tools to successfully enforce safety regulations or maintain long-running safety plans. 

At Berg Compliance, we understand that frustration. That’s why we offer affordable, customizable, and flexible compliance programs for manufacturers of all sizes.   You can’t afford to wait for a budget-crushing fine or employee injury to create an OSHA-compliant EAP. Call 512-457-0374 or click here to schedule your free consultation today